BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-9061
RECEIVEI)
hc 21
2 13 P/j ‘.97
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OFFICE 0; THE ~~~~~~~~~~~
Postal Rate and Fee Changes, 1997
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Docket No. R97-1
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO UNITED STATES POSTAL SEF!VICE
WITNESS JOSEPH D. MOELLER
(OCA/USPS-T36-25-26)
August 21, 1997
Pursuant to sections 25 and 26 of the Rules of Practice of the Postal Rate
Commission,
the Office of the Consumer Advocate hereby submits interrogatories
requests for production of documents.
and
Instructions included with OCA interrogatories
l-7 to the United States Postal Service dated July 16, 1997, are hereb’y incorporated
reference.
Respectfully submitted,
GAIL WILLET-TE
Director
Office of the Consumer Advocate
SHELLEY S. DREIFUSS
Attorney
by
Docket No. R97-1
OCWJSPS-T36-25.
the letter/non-letter
a.
2
In USPS-T-36 at 27, you propose a zero percent passthrough
of
differential for the Basic ECR letter tier.
Please confirm that there is a unit cost differential between Basic ECR letters
and Basic ECR flats which is equal to 3.5099 cents; i.e., 10.38414 cents (unit mail
processing and delivery cost for basic ECR non-letters) -
6.8745 cents (unit
mail processing and delivery cost for basic ECR letters) = 3.5099.
USPS-29C,
[Source:
page 21 If you do not confirm, explain why and provide the correct
figure, including calculations and citations.
b.
Also confirm that in PRC Op. MC951,
basic, carrier-route,
para. 5593, the Commission
held that a
unit cost differential between letters and flats of 1.6 cents
was of sufficient magnitude that it must not be ignored and that to do so “would
be contrary to the Act.” If you do not confirm, please explain.
C.
Confirm that in PRC Op. MC95-1, page V-265, Table V-5, the Commission
calculated a Basic ECR letter/non-letter
unit cost differential of ‘I .3563 cents,
If
you do not confirm, explain why and provide the correct figure, includingcalculations
d.
and citations.
Confirm that the Commission
differential,
applied a 40-percent
passthroughr of the
yielding a discount of 0.5 cents (rounded).
Id. If you do not confirm,
explain why and provide the correct figure. including calculation,s and citations.
e.
Isn’t it true that the cost difference between Basic ECR letters alnd Basic ECR
non-letters
has more than doubled since it was last reported in Docket No.
Docket No. R97-1
MC95-I?
3
If you do not confirm, explain why and provide the correct figure,
including calculations
f.
and citations.
Confirm that a 40-percent
passthrough
of the Docket No. R97-1 cost differential
(3.5099 cents, as described in subpart a.) would yield a discourrt of
approximately
1.4 cents for Basic ECR letters,
If you do not confirm, explain why
and provide the correct figure, including calculations and citations.
Isn’t it correct that when you balance the “special consideration”
Service’s letter automation
program against letter/non-letter
of the Postal
cos,t differences,
you
reach a conclusion opposite to that reached by the Commissiorr in PRC Op.
MC95-l?
h.
If you do not agree, please explain.
Isn’t it correct that one of the assumptions
relied upon by the Postal Service in
Docket No. MC95-1 to justify its decision not to propose a lower rate for ECR
letters was information
given to Postal Service witness McBride that “the letter-
flat cost differential would decrease in the future because of the shift to vertical
flat casing?”
PRC Op. MC95-1, para. 5575. If you do not agree, please explain
why.
i.
Isn’t it also true that, contrary to Postal Service expectations
at the time Docket
No. MC95-1 was being litigated, the letter/flat differential has grown
substantially?
If you do not agree, please explain.
Docket No. R97-1
4
OCAfUSPS-T36-26,
a.
Please confirm that, in USPS-T-18 at 15, Docket No. MC95-1, you proposed perpiece rates for pound-rated
ECR that were of roughly the same magnitude
those you propose in the current proceeding.
USPS-proposed ECR Per-PC Rates,
Docket No. MC95-1
(Cents)
Basic:
High-density:
Saturation:
[See comparison
as
below]
USPS-proposed ECR Per-PC Rates.
Docket No. F197-1
(Cents)’
Basic:
High-density:
Saturation:
5.0
4.3
3.0
5.!j
4.4
3.2
If you do not confirm, please explain
b.
Also confirm that the Commission
instead recommended
Basic:
High-density:
Saturation:
rejected per-piece rates of this magnitude
and
the current rates, which are:
1.8
1.0
0.0
If you do not confirm, please explain.
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing document
participants
upon all
of record in this proceeding in accordance with section I;! of the rules of
practice.
/Lbuhp§.
JLg.&
SHELLEY S. DREIFUSS
Attorney
Washington, D.C. 20268-0001
August 21, 1997
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